Frequently Asked Questions about the Responsible Digital Payments Guidelines

1. Why were the Guidelines developed?
The Guidelines were developed as part of the Better Than Cash Alliance’s commitment to accelerating the transition from cash to digital payments in a way that promotes responsible digital payments.

2. What do you mean by “responsible” digital payments? What is the purpose of the Guidelines?
The Guidelines are a tool for all stakeholders who want to build a responsible digital payments market for the financially excluded and underserved, which shows respect for clients and encourages the access and use of digital payments systems.

3. Who are the Guidelines designed for?
The Guidelines are primarily oriented toward financial services providers to help them design and deliver their digital payment services. Subject to applicable law, they can also be useful for:

• Regulators in developing rules;

• Private sector (for example, fast-moving goods or transport companies) in selecting payment providers;

• Donors and development organizations in procuring services from payment providers; and

• All stakeholders in advocating for appropriate consumer protection.

4. How were the Guidelines developed? Who’s behind them?
The Guidelines reflect several years of consultations about the nature and importance of responsible digital payments. Discussions took place between regulators, payment service providers and makers and international development agencies.

The global consultations and meetings included the 2013 Financial Inclusion 2020 Financial Inclusion Global Forum and the Responsible Finance Forums in 2014-2016 (RFF Forums) on responsible digital finance. The RFF Forums were held in conjunction with the G20 Global Partnership for Financial Inclusion meetings. Guidance also came from the 2015 Better Than Cash Alliance Mapping of Principles, Standards, and Codes of Conduct in Digital Financial Services, and other international research and reports. The draft Guidelines were also shared broadly for comment.

5. What were the underlying principles applied in developing the Guidelines?
The underlying principles were that the Guidelines should:

• Focus on issues relevant to financially excluded and underserved clients;

• Be technology and provider neutral;

• Only apply to digital payments initially;

• Be flexible enough to cover other digital financial services in the future, with minimal changes;

• Be relevant to all stakeholders in the digital payments ecosystem. This includes all clients, regulators, payment service providers and makers and international development agencies.

6. How do the Guidelines fit in with other principles, standards and codes covering client protection issues in the payments system?
The Guidelines are intended to synthesize key aspects of other relevant principles, standards and codes, and to address any gaps. Guidance in this regard was obtained from the Payments Aspects of Financial Inclusion Report (2016) from the joint task force of the Committee for Payments and Markets Infrastructure (CPMI) and the World Bank Group; the Responsible Finance Forum VI Evidence and Innovation for Scaling Inclusive Digital Finance Report (2015); the Bill & Melinda Gates Foundation Level One Project Guide (2015); the Responsible Finance Forum V Responsible Digital Finance Outcomes Report (2014); the GSMA Code of Conduct for Mobile Money Providers (2014); the World Bank Global Good Practices on Financial Consumer Protection (2012); the G20 High-Level Principles on Financial Consumer Protection (2011); and the Smart Campaign Client Protection Principles (2011).

7. What is the link between these guidelines and the G20 High Level Principles for Digital Financial Inclusion?
The Guidelines were developed in parallel with the G20 High-Level Principles for Digital Financial Inclusion (2016) (G20 HLPs). The G20 HLPs themselves were built on the G20 Principles for Innovative Financial Inclusion (2010), which recognized the importance of responsible practices in financial inclusion in the wake of the financial crisis. The G20 HLPs provided a basis for country action plans reflecting country context and national circumstances to leverage the huge potential offered by digital technologies. The G20 HLPs deal with all aspects of digital financial inclusion. The Alliance’s Guidelines are more specific and focus on consumer protection issues affecting financially excluded and underserved clients using common types of digital payments products, such as electronic money transaction accounts. They can be used as a guide to implementing consumer protection aspects of the G20 HLPs (see especially Principle 5 – Establish Responsible Digital Financial Practices to Protect Consumers).

8. The Guidelines only cover digital payments – could they also cover other digital financial services such as micro loans or insurance products provided over mobile phones?
While the Guidelines are focused on digital payments, many aspects are relevant to other digital financial services. For example, Guidelines 1, 3, 4, 6, 7, and 8 are all potentially relevant to any digital financial service. However, the examples of each Guideline might change depending on the type of service being provided. Further, there may be a need for additional Guidelines for particular services – such as a Responsible Lending Guideline for digital credit services.

9. Will the Guidelines be updated?
The Guidelines may need to be reviewed and updated from time to time. However, they are designed to be “technology neutral” so they can apply to innovations that emerge in the field of digital payments.

10. Will the Better Than Cash Alliance monitor implementation of the Guidelines?
No. However, the Alliance is always interested in hearing from stakeholders about their experiences in implementing the Guidelines. The Alliance is also happy to share any “lessons learnt” with the agreement of the relevant stakeholder.

11. Will the Better Than Cash Alliance publish case studies on implementation of the Guidelines?
Yes. The Alliance is planning to publish in 2018 a series of short case studies (“caselets”) on experiences in implementing the principles reflected in the Guidelines. They will reflect the experiences of providers, regulators, and payment makers.

12. Where can additional updates and information on the Guidelines be found?
The Alliance will publish any advice on its website and also make its publications available at global forums such as meetings of the Responsible Finance Forum and the G20 Global Partnership on Financial Inclusion.

For suggestions and comments regarding updates to the Guidelines, or if your organization has a case relating to one of the eight guidelines that may be relevant to others implementing the Guidelines, please contact Beth Porter at beth.porter@uncdf.org and Angela Corbalan at angela.corbalan@uncdf.org.